ML20148E664
| ML20148E664 | |
| Person / Time | |
|---|---|
| Issue date: | 10/03/1980 |
| From: | Minogue R NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML19252A551 | List: |
| References | |
| FOIA-81-97, TASK-OS, TASK-SC-014-1, TASK-SC-14-1 NUDOCS 8010280540 | |
| Download: ML20148E664 (2) | |
Text
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MEMORANDUM FOR: H. R. Denton, Director Office of Nuclear Reactor Regulation
'FROM: R. B. Minogue. Director, OSD SU8 JECT: STANDARD FOR QUALIFICATION OF SAFETY RELATED EQUIPMENT i
This letter responds to your letter of September 2,1980, requesting us to
" evaluate the aavisability of developing in a broad single rulemaking action an amendment to 10 CFR 50 which would include 1) the rulemaking directed by the Comission, ca environmental qualification of electrical equipment (CLI-80-2{,
[ 2) the rulemaking proposed in the Comission paper from I&E (SECY-80-139), on
! independent verification and testing and inspection of equipment's environmental qualifications, and 3) broadly address the qualification of both electrical and mechanical equipment (including chemical process equipment such as hydrogen recombiners) for seismic and dynamic loading conditions as well as other environ-mental conditions."
i Your proposal, that a comprehensive r51emaking addressing all aspects of qualifi- l cation of all type of safety related equipment be developed, has merit. However, we do have a concern that the expanded assignment could cause delays in completing the highest priority. item, namely the Comission order, since there is a wide variance in the status of: 1) time commitments and estimated completions for those phases of the program already in process, and 2) available supporting NUREGS, Rog. Guides and National Standards.
! A number of standards and regulatory guides are available on qualification of I i electrical equipment, whereas some standards are in varying stages of development I
and no regulatory guides ut presently available on qualification of mechanical equipment. Without the detailed standards required for implementation, the rule i could be judged impractical. Therefore, due to the deficiency in mechanical equip- !
ment standards, we are considering an advance notice of proposed rulemaking for the broad rule.
Since receipt of your letter, we have leAcned that the independent verification , ;:
j i testing may programto is be broadened to include cover far more than a third partyqualification.
equipment accreditation system and the I /
, In view of these coglications, we believe it to be more expedient to start the l project as three separate and concurrent items whh.n we will attempt to consolidate r
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,, 1 H. R. DentcL 2 OCT 3 1980
- into a single'pbckage as shown in the enclosure. This approach will provide
- more flexibility in the event any single portion of the task could be completed early, or. if the progran is modified. It it appears that each phase requires a hearing, we would attempt to combine the rules for a single hearing.
l The entire program is an extensive undertaking and will require careful monitoring
-l and inputs and agreements from NRR and I&E. We can't lost-sight of the Commissioners l
OrderrequiringtheelectricalequipmentqualificationrulemakingsinceithasouR highest priority. At present, it is also the ites with the most- potential for early release.
In conclusion, we plan to start the program as 3 separate and concurrent items which"will attempt to consolidate into the single package you requested. Clari-fication and justification for this plan will be more evident and can be more readily finalized after the program is better defined with Task Initiation Forms and Preliminary Value Impact Statements.
! We will maintain close contact with your staff to diset/ss progress, problems and any modifications to the program. A preliminary scheoule outlining this under-taking is enclosed.
OM8 1::a gy maan.C n mg i
Robert B. Hinogue, Director
- Office of Standards Development
Enclosure:
Preliminary Schedule l
CONTACTY H. I. Gregg.
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